The WFE welcomes the opportunity to respond to the Commodity Futures Trading Commission's (CFTC) Request for Comment on the Trading & Clearing of “Perpetual” Style Derivatives. Our response focuses on the implications of perpetual derivatives for global market structure, market integrity, systemic stability, and the fair and orderly functioning of financial markets, providing a high-level perspective informed by global practices across our diverse membership base. While perpetual derivatives are not a substitute for traditional futures in all contexts, they may serve as a valuable complement in the broader toolkit for risk transfer and price formation - particularly in new or fast-evolving markets. We commend the CFTC for its proactive engagement with this emerging product class and trust that our insights will support the Commission's efforts to ensure robust, transparent, and resilient markets.